Mark Hoff v. State, 07-15-00011-CR

Appellant Hoff indicted for Possession of a Controlled Substance in a drug-free zone; evidence suppression motion heard Sept. 3, 2014; trial court denied suppression and Hoff pled guilty Nov. 20, 2014; sentence seven years with ten-year community supervision; appeal follows.
Search warrant issued for Hoff's residence based on confidential informant; methamphetamine, pipe, and pills found; Hoff allegedly ingested meth during search.
Investigator Clint Andrews coordinated narcotics unit; confidential informant claimed Appellant possessed meth at residence within 48 hours; corroborating information included by multiple narcotics officers.
Detective Ragan advised Hoff of Miranda rights; Hoff admitted ingesting narcotics; statement was not recorded.
Affidavit argued to provide probable cause due to informant reliability and corroboration; Duarte distinguished due to corroboration in this case.
State contends the trial court did not err in denying the suppression motion; the magistrate had probable cause based on reliable informant with corroborating facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the suppression denial proper due to probable cause?	Hoff contends insufficient probable cause.	State argues informant credible; corroborated by officers.	Yes; denial affirmed.

Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (bifurcated standard; deference to historical facts; de novo legal review)
State v. Duarte, 389 S.W.3d 349 (Tex. Crim. App. 2012) (informant reliability; corroboration needed)
Dixon v. State, 206 S.W.3d 613 (Tex. Crim. App. 2006) (reliability of confidential informants; 'successful track record')